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Is a Roof Warning Line OSHA Compliant?

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One common question people ask about work on low slope roofs concerns warning line use. Specifically, clients ask: “Are rooftop warning lines OSHA compliant?”

Close-up of warning line marker

Close-up of warning line marker

The short answer to this seemingly simple question is “it depends.”

Here are the factors you need to assess…

For work scenarios less than six feet from the roof edge, per OSHA 1910.28(b)(13)(i), employers must protect workers from falling with a guardrail system, safety net system, travel restraint system, or personal fall arrest system.

Put another way, warning lines are not an OSHA compliant form of fall protection under these circumstances.

Per OSHA 1910.28(b)(13)(ii), when work is performed at least six feet but less than fifteen feet from the leading edge, employers may protect employees from fall hazards with a passive restraint guardrail system, safety net, travel restraints system, or a personal fall arrest system.

Designated area warning line

Designated area warning line

If your employees perform maintenance and/or repair activities at least six feet but less than fifteen feet from the roof edge, OSHA also allows “designated areas” delineated by a warning line, assuming the work is infrequent and temporary in nature.

Strength, Visibility Also Factors

It’s important to note that distance from the edge of the roof and the frequency of work are not the only factors that determine the OSHA compliance of a warning line.

To ensure full compliance per OSHA 1910.29(d)(2), Employers must ensure that warning lines meet additional criteria, including:

  • Has a minimum breaking strength of 200 pounds (0.89 kN); [1910.29(d)(2)(i)]
  • Is installed so its lowest point, including sag, is not less than 34 inches (86 cm) and not more than 39 inches (99 cm) above the walking-working surface; [1910.29(d)(2)(ii)]
  • Is supported in such a manner that pulling on one section of the line will not result in slack being taken up in adjacent sections causing the line to fall below the limits specified in paragraph (d)(2)(ii) of this section; [1910.29(d)(2)(iii)]
  • Is clearly visible from a distance of 25 feet (7.6 m) away, and anywhere within the designated area [1910.29(d)(2)(iv)]

For work performed fifteen feet or more from the roof edge, per OSHA 1910.28(b)(13)(iii)(A), employers have the option of protecting employees with guardrail, safety nets, fall restraint systems, fall arrest systems, or a designated area.

Employers are not required to provide any fall protection under this scenario (i.e., low slope roof work done more than 15 feet from the edge) assuming the rooftop activity is both infrequent and temporary.

Parting Thoughts

A warning line system serves primarily as a visual reminder. Warning lines do not prevent an actual fall. Safe use of warning line systems on low slope roofs requires employers to ensure employees remain within the designated area while work operations are underway. Although a given work area may be deemed OSHA compliant with a warning line in place, it is important to remember the training and diligence aspects of keeping your workers safe at heights.

To get your specific questions answered about warning lines or any other OSHA fall protection requirements, contact the safety specialists at Diversified Fall Protection. Our job is to help you keep employees safe so EVERYONE goes home at the end of their shifts.

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Did You Know?

There were 6,271 cited Fall Protection OSHA standards violations in 2015?